DOT-SP 7887, DOT-SP 7887 Show Cause Letter and Estes’ Response
the following was sent by Estes to some vendors. Re-posted with permission.
URGENT NOTICE– YOUR SUPPORT IS NEEDED
Re: DOT-SP 7887, DOT-SP 7887 Show Cause Letter and Estes’ Response
Attn: Model Rocketry Product Manufacturers:
As a participant and supplier in the world of model rocketry, we believe you have a stake in the shipping of model rocket engines and igniters. We are writing to advise you of recent developments and to ask for your action and support.
On August 15, 2011 all grantees authorized to use DOT – SP 7887 received a Show Cause letter from the US Dept of Transportation (DOT). The Special Permit, DOT – SP 7887 allows the shipment of model rocket motors (engines) and igniters in limited quantities to be shipped as Flammable Solids. The Show Cause letter advised that additional testing of model rocket motors is needed to determine if they may be excluded from the classification of Explosives. After an evaluation of the testing to which the letter referred, it was determined that model rocket motors would not meet the criteria for exclusion.
The letter further advises that whether or not model rocket motors meet the criteria, DOT is proposing to terminate the Special Permit. The Special Permit has been in place since 1978. In 33 years there have been no incidents involved in the shipping and transporting of model rocket motors and igniters.
Model rockets, engines/motors and their igniters are shipped to educators, youth group leaders, children and their families for educational and recreational purposes. Model rocket motors and igniters have an excellent record with regard to shipping and transportation. We are very concerned that having to use an Explosives label on packages of engines and igniters projects a frightening message and an exaggerated risk to those receiving the packages. Model rocket engines and igniters do not ignite spontaneously and they don’t EXPLODE. They are propellant devices.
Shipping engines and igniters as 1.4S explosives is not a great deal more difficult from a technical standpoint nor is it a lot more expensive. However, the word “explosives” on a bright orange hazardous materials label creates more concern than does a flammable solid label! Boxes of model rocket engines and igniters sitting in the back rooms of hobby shops, large distribution centers, wholesalers’ warehouses and school supply closets will likely garner far more attention from fire prevention personnel, insurance investigators, school administrators, OSHA inspectors and most importantly from the parents of young rocket enthusiasts!
Therefore, Estes as well as Quest Aerospace and RCS/Aerotech have sent responses to the US DOT requesting that the Special Permit, DOT – SP 7887 not be terminated. And we are asking re-shippers of our products to send responses to DOT as well as this will impact their shipments.
As a supplier of model rocket products, you too have an interest in the future of DOT-SP 7887. Termination of the Special Permit may have a very negative and long-term impact on our hobby.
If you believe as we do, that termination of the Special Permit is not warranted, we ask you to send an email or letter via email supporting our requests to keep the Special Permit in place and to protest its termination. The email or letter or both should be sent to DOT as soon as possible and preferably prior to October 2, 2011. To assist you, a sample letter is enclosed that you may customize.
The email address to which emails and letters should be sent is: email@example.com Please use “DOT-SP 7887 Show Cause Response” as the email subject. To assist us, please bcc firstname.lastname@example.org or one of the other engine manufacturers.
As you will note in Estes’ response to the Show Cause letter, we intend to petition for permanent relief. If we are to succeed we will need the support of the industry and consumers alike.
Therefore we again ask for your support and action on this important issue. Thank you. We will keep you up-dated!
Copies of the Special Permit, Show Cause Letter, Estes’ Response and Sample Letter are attached.
(Only the show response letter has been attached as a pdf. Originally sent as a .docx file)
To make it perfectly clear, only manufacturers and suppliers (those who sell and ship model rocket motors) should write letters.
End users should stand by and support the manufacturers and suppliers.
Or did Mary request that end users/consumers write and submit a flood of letters??? I'm too busy to call and ask and since you have persmission to repost this info, I assume you can get official clarification and post that here.
the letter was addressed to vendors.
Here we go again. Stand by for more useless and irritating government regulation changes.
Hope and Change are still alive and well........
Oh, 'change' is certainly alive, but I'm not certain that I'd put the 'well' label on it.
'Hope', I'm afraid to say, may have caught the last train to Clarksville some months ago.
In my opinion, yet another instance where someone wants to make changes simply to validate having their job!
folks this is being forced upon us by the fedgov's desire for UN harmonization......with their Transport of Dangerous goods
Harmonization - straight out of 1984's NewSpeak
End User/Consumer Response
Perhaps an opprtune time to chime in with regard to the proposed suspension of DOT-SP 7887 regarding the labelling of rocket motors as flammable materials as opposed to Explosives. Estes published a pro forma in their recent email subscription service which would seem beneficial to all that ship motors either as consumer, wholesaler, or retailer.
The address to which the response should be sent is:
The subject line should be:
DOT-SP 7887 Show Cause Response
Suggested copy for the email:
Dear Associate Administrator,
The purpose of this e-mail is to request that DOT-SP 7887 be kept in force as written. The Special Permit, previously DOT-E 7887 has been in place since 1978 and is used by many of us who enjoy hobbies including model rockets, motors and igniters.
To my knowledge, there has never been a reported incident involving the shipping or transporting of model rocket motors and igniters. Further, I believe that shipping these products as "Explosives" with attendant packaging requirements will create unnecessary fear and difficulty for those handling, transporting, receiving, storing, selling and using these products. Moreover the labelling as such will instill into the hobby a sense of public concern that that is both inappropriate and unwarranted.
After 33 years of use, the termination of the Special Permit is neither required, nor in the best interest of the public. Moreover such a move would be assuredly damaging to an educational and recreational product that has an excellent record. In closing, I again request the Special Permit be kept in place as written.
Include your name and address here
Sent mine yesterday. I modified the suggested letter slightly, mentioning schools and education.
I just sent mine as well.... also emphasizing the school/youth group/education angle.
The NAR just sent out a mass mailing encouraging us to to this, too.
This is 27 CFR 55.141(a)(7) from 1991 which was changed in 1998. Our guy Shultz posted on his blog, "As you might recall, 27 CFR 55.141(a)(7) exempted Class C toy propellant devices until BATF screwed up a change in 1998 by forgetting to list anything but fireworks."
The NAR/TRA lawsuit was filed in 2000 in response to the ATF change of 27 CFR 55.141(a)(8) and the order was finally entered 16 March 2009. Both changes were made about the same time (a)(7) and (a)(8). It was not a mistake.
In fact DOT stated DOT Class C and DOT or UN 1.4 as equivalent. Therefore the only change needed was referencing DOT or UN 1.4. This change is the source of "starters" since they and all Class C articles (igniters, fuse, motors) were exempt until 1998. Still are under NA-0323 in the motor packages.
Proposed language 27 CFR 555.141(a)(7): (Revision 2016)
(7) The importation and distribution of fireworks classified as DOT or UN 1.4 articles and generally known as "common fireworks", and other DOT or UN 1.4 articles and substances, as described by the U.S. Department of Transportation regulations including in 49 CFR 173.100 (p), (r), (t), (u) and (x).
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